PRGX Global, Inc.
Global Privacy Policy
Updated: January 2010

U.S. - EU Safe Harbor Privacy Statement
For personally identifiable information of employees, clients, healthcare providers, professionals and customers, investors, and government officials that PRGX USA, Inc. receives from the European Economic Area, including Switzerland, PRGX USA, Inc. has committed to handling such personal information in accordance with the Safe Harbor Principles.

PRGX USA, Inc.’s Safe Harbor certification can be found at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.

For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s Website at http://www.export.gov/safeharbor/.

Social Security Number Protection Statement
PRGX Global, Inc. (collectively referred to in this Statement as “we,” “our,” or “us”) collects Social Security Numbers in the ordinary course of its business, such as from our employees, as well as in certain records we process for our clients. We have implemented reasonable technical, physical and administrative safeguards to help protect the Social Security numbers. All of our employees are required to follow these established procedures. In particular:

• Access to Social Security Numbers is limited to those employees and service providers who have a need to access the information to perform tasks for us and our clients.
• Social Security Numbers are only disclosed to third parties in accordance with our established policies. We only disclose Social Security Numbers to (i) those service providers, auditors, advisors, and/or successors in interest who are legally or contractually obligated to protect them or (ii) as required or permitted by law.

If you have any questions, please contact us at: .(JavaScript must be enabled to view this email address).

Global Privacy Statement

Introduction
PRGX Global, Inc. and its subsidiaries and branches (collectively referred to in this Statement as “we,” “our,” or “us”) are committed to respecting and protecting the privacy of individuals with whom we come into contact including our employees, our clients, our suppliers and vendors, our investors and those individuals who browse and use our website.

Personally identifiable information (PII) is information that can be used to identify or contact an individual. PII includes, but is not limited to, name, home address, email address, phone number, government issued ID (i.e. SSN, SIN, driver’s license number), and health and benefits information.

PII of our job applicants and employees is protected by the Employee Privacy Statement. The Employee Privacy Statement is also available on our company intranet site, by emailing .(JavaScript must be enabled to view this email address), or by contacting their local HR manager.  This Global Privacy Statement (“Statement”) governs our collection, use, disclosure and processing of all other PII, such as PII that we receive from our clients, our suppliers and vendors, our investors and those individuals who browse and use our website.

The purpose of this Statement is to explain the types of information that we collect, what we do with that information, and with whom we share this information.

How do we collect, use and disclose PII?
We are a business-to-business service provider, and as such we process data on behalf of our clients. We collect transactional data (most commonly, accounts payable) from, or on behalf of, our clients in order to perform the requested services. In some cases, we collect healthcare related data from, or on behalf of, our clients when auditing transactions or providing other services for clients in this industry. Information obtained from or relating to clients or former clients is subject to the terms of any contractual arrangements with the client, this Statement, as well as applicable laws and professional standards.

When we collect PII, our use of PII is limited to:

• the purposes stated in the applicable notice or consent form,
• other purposes for which the individual would reasonably expect the information to be processed,
• other purposes as required or permitted by law,
• customary internal purposes, such as benchmarking, reporting or quality assurance purposes, and
• to contact you about products and/or services that may be of interest.

Use by Third Parties
PII provided to us may, in limited circumstances, be shared with third party service providers. We screen third parties that would receive such information and review the intended use of the data before providing any information to them.

We may use contractors and other service providers to help us deliver a service and fulfill requests of our clients. In these circumstances, we ensure that appropriate contracts are executed.  Contractors and service providers are required to adhere to our privacy and security policies.

 

In addition, and at the request of a client, we may provide that client’s data to a third party for additional services arranged by the client.

We may also provide aggregate data (not including any PII) to third parties for various purposes, including facilitation of the improvement of services we provide to our clients.

Please note that we may use or disclose any information as required by law, when necessary for health or safety purposes, or when needed to protect our legal rights. For example, we may disclose information in response to a subpoena or court order. We may also disclose information in connection with the transfer or sale of our business.

Security and Protection of PII
We have implemented various physical, electronic, managerial and administrative measures, including education and training of our employees, to provide reasonable protection of PII from accidental loss or destruction, improper use, alteration, or disclosure. We have invested in and deployed a wide variety of technology and security features for the privacy and security of PII. Access to PII is granted on a need-to-know basis. In addition, we require that all employees sign confidentiality agreements.

Cookies
Cookies may be used on some pages of our site.  “Cookies” are small text files placed on your hard drive that allow us to statistically monitor how many people are using our site and for what purposes.  This information helps us dynamically generate web content and design web functionality specifically for users of our site.  Cookies used on our site do not collect any Personal Information and they cannot retrieve data from a user’s hard drive or obtain the user’s email address.

Choice, Access and Correction
With regard to the PII that we collect, we are committed to respecting individual rights of choice, access and correction. Individuals may submit access requests, ask questions or object to our processing of their PII by contacting us at .(JavaScript must be enabled to view this email address). We will use reasonable efforts to respond to all such requests in a timely manner.

With respect to PII provided to us by, or on behalf of, our clients, we recommend that you contact the client directly to seek access to and to correct, amend, or delete inaccurate data. If you need assistance, please contact us and we will request our clients to correct, amend or delete any erroneous information, subject to their own policies and instructions.

Enforcement of this Statement
For disputes arising under our Safe Harbor certification, we will cooperate with the European Union Data Protection Authorities and the United States Department of Commerce to resolve any complaints and disputes arising in connection with this Statement. For all other disputes, we will investigate any reported complaints of violation of this Statement and take what we believe to be appropriate action where violations are found. If you have questions about our Statement or how we handle PII, please contact us at .(JavaScript must be enabled to view this email address).

Information about Children
We do not knowingly provide products or services to or solicit information from children under the age of 18.

Changes to this Statement
From time to time, we may decide to make changes to this Statement. If we make a material change, we will post the revised statement and highlight the change in this section of the Statement. We will not apply any material changes retroactively unless we have notified you and given you a chance to object.

January 20, 2010:
As part of the launch of our new PRGX website, the “Cookie” section of this Statement has been updated to reflect new and limited uses of cookies which are used to monitor the traffic and use within our site as well as to enhance web content and functionality.  Cookies on our site do not collect personal information.

Questions
Questions about our Statement may be sent by email to: .(JavaScript must be enabled to view this email address).

This Statement was last updated on January 20, 2010.

Employee Privacy Statement
Respecting the privacy of our employees is important to PRGX Global, Inc. and its subsidiaries and branches (collectively referred to in this document as “we,” “our,” or “us”). We are committed to the proper handling of personally identifiable information (“PII”) collected or generated in connection with your employment. PII is any information that can be used to identify or contact an individual. PII includes, but is not limited to, name, home address, email address, phone number, government issued ID (i.e. SSN, SIN, driver’s license number), and health and benefits information. This Employee Privacy Statement (“Statement”) explains our practices with regard to employee PII.

1. We take reasonable steps to protect your PII.
2. We collect, process, and transfer employee PII through electronic and paper-based data processes. We have established routine processing for certain functions relating to your employment (such as processing for regular payroll and benefits administration). We also process employee PII on an occasional or ad hoc basis (such as when an employee is being considered for a new position). All processing and transfers of PII are subject to confidentiality and privacy safeguards as set forth in this Employee Privacy Statement, our Security Policies and applicable laws. PII will not be collected, processed or transferred, except where adequate privacy protection mechanisms are in place and, if required by law, after having first obtained consent.
3. We process employee PII for the following purposes: (1) recruitment and staffing; (2) administration of compensation and benefits programs; (3) performance management and training; (4) advancement and succession planning; (5) legal compliance and risk management; (6) workplace management and reporting; (7) protection of our company, our workforce, and the public against injury, theft, legal liability, fraud or abuse; and (8) other customary and legal business-related purposes.  If you, at any time, object to your PII being processed, you may contact your local Human Resources manager. Where reasonable, we will accommodate your request, although if we cannot process your information you may be denied certain benefits. 
4. We will disclose your personal information only (1) among our affiliated companies (including our subsidiaries and branches) for purposes stated in this Statement (2) to data processors, who we contract for specific purposes, (3) to companies who provide benefits and services to you (such as retirement plans), (4) where required by law, or (5) where permitted by law, such as with your consent or in the event of an emergency.
5. Bear in mind that employees and applicants share responsibility for the accuracy of their personal information. Please let us know when changes to your personal information are needed by contacting your local Human Resources manager.
6. We are also committed to protecting the privacy of our clients, visitors to our website, and of our vendors. Employees are expected to follow the company’s security and privacy policies and procedures when accessing and handling client, vendor and website visitors’ data.
7. If you have questions or concerns with respect to the personal information we have about you, please contact the Human Resources or Privacy Departments.

Tiffany Glover
VP, Human Resources
770-779-3240
.(JavaScript must be enabled to view this email address)

Alicia Jackson
VP, Privacy
770-779-3042
.(JavaScript must be enabled to view this email address)
.(JavaScript must be enabled to view this email address)

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